Vendor Guru Q&A - Compliance

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Latest Compliance - Reg. BB Topics

How to Report Revolving Lines of Credit (Extended)

10/01/2017

I am trying to obtain a good definition and/or guidance on how to report Revolving Lines of Credit that have been extended and not renewed for a particular year. Example – A customer has a revolving line of credit for $250,000 that originally was executed in November 2014 and is up for renewal in November 2015, however the borrower has asked for a 3-month extension which the bank granted, the amount and conditions are unchanged. For 2015 reporting, can we/should we be reporting/treating the $250,000 as a renewal/extension that took place in 2015? Or not report it as it was an extension and not a renewal according to the CRA quidelines?

CRA Reporting of Gross Revenue (Reg BB)

08/13/2017

The CRA regulation states, "generally, an institution is to rely on the revenues that it considered in making its credit decision." It also states, "The regulation does not require institutions to request or consider revenue information when making a loan; however, if institutions do gather this information from their borrowers, the agencies expect them to collect and rely upon the borrowers' gross revenue for purposes of CRA." Does one of these trump the other? We use personal income for the credit decision and rarely use gross revenues of the business. Our auditors think the "credit decision" amounts outweigh using what we have in the file. If we only used the credit decision amounts, we wouldn't have many loans to report.

Documentation to Prove Community Development Loan

05/25/2015

What documentation would you suggest to prove a community development loan with the purpose of revitalization/stabilization in a moderate- income area? We are financing the purchase and construction of a mixed use development with upper income housing, retail and commercial space. The housing units have been completed but our loan will finance the finish out of the retail/commercial space. Development has TIF credits that our borrower will receive.

How to Complete a CTR for an Estate

10/13/2019

How would I complete a CTR for an estate? The Trust Dept. opened deceased customer's safe deposit box and found $75,000 in cash. Funds were then deposited into a trust fund. I know the trust employee will be the transactor but how do we handle the "on behalf of"? Do we just put customer's name even though he is deceased? There's no where to put "The Estate of ..."

US Person and NRA on account? Whose TIN?

10/13/2019

If there is a US Person and a Nonresident alien on the account, do we have to have a FTIN?

Get in the FDIC's Good Graces: Qualifying for the CBLR Framework

10/13/2019

What is the Grace Period for the Community Bank Leverage Ratio (CBLR) Framework?

How Long to Sign Forms for Fraudulent Checks

10/13/2019

We have a customer that we suspect may have several fraudulent checks written against her account. How long does she have if they are fraudulent, to sign the forms that they are fraud?

Trust Agreement Need to be Signed/Notarized?

10/13/2019

We have a business organized as a trust that is opening an checking account for a bingo unit. There is only one person named in the Trust Agreement. His name is Mike. Mike is named as a trustee/designated agent in the Trust Agreement. He is wanting to add his bookkeeper, Kim, to be an agent on the account. Is this allowed for trust accounts, or are only people designated in the Trust Agreement allowed to be on the account? Also, the Trust Agreement is not signed or notarized, which raised some questions for our New Accounts Rep. Does the Trust Agreement need to be signed and/or notarized?

Latest Compliance - Reg. BB Topics

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